§ PDF page 19
1. If in one of the Contracting States the taxes on dividends, interest, royalties, or other items of income derived by a resident of the other Contracting State are levied by withholding at source, then the right to apply the withholding of tax at the rate provided for under the domestic law of the first-mentioned State is not affected by the provisions of this Agreement.
§ PDF page 19
2. The tax so withheld at source shall be refunded on the taxpayer’s application to the extent that its levying is limited or eliminated by this Agreement. The period for application for a refund of the tax withheld is four years from the end of the cal- endar year in which the dividends, interest, royalties, or other items of income have been received.
§ PDF page 19
3. Notwithstanding paragraph 1, each Contracting State shall provide for procedures to the effect that payments of dividends, interest, royalties or any other items of income which are subject under this Agreement to no tax or only to reduced tax in the State of source may be made without deduction of tax or with deduc- tion of tax only at the rate provided in the relevant Article.
§ PDF page 19
4. The Contracting State in which the income arises may require the taxpayer to provide certification of his residence in the other Contracting State issued by the competent authority of that other State.
§ PDF page 19
5. The competent authorities of the Contracting States may determine the mode of implementation of this Article by mutual agreement and if necessary establish other procedures for the implementation of tax reductions or exemptions provided for under this Agreement.